Milner v. Department of the Navy

Summary

The Court held that FOIA Exemption 2 covers only records concerning employee relations and human resources. Because the Navy's explosives data and maps do not relate to personnel rules, they are not exempt under Exemption 2. Justice Breyer dissented, arguing for continued adherence to the D.C. Circuit's broader interpretation in Crooker. Justice Alito concurred, noting other exemptions might protect the data.